Prepared by Anna Ielisieieva, 4 th year student, International Economics, KROK University for Economics and Law

1.Economic Essence of Transfer Pricing 2.Transfer Pricing Regulation in Developed Countries 3.Transfer Pricing Regulation in Ukraine Current Challenges Recommendations

Basic Characteristics 1.Regulation inside a company. 2.Meeting particular needs. 3.Generation of the inner profit rate. 4.Influence on macroeconomic indicators. 5.Manipulation by a TNC.

TNC’s Motives  transfer of money;  decrease of tax duties;  impact on customs tariffs;  different risks;  other.

Organization for Economic Cooperation and Development Transfer PricingInternational Taxation 30 members

OECD Main Document “ Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”, 1995 “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”, 1995  The Arm’s Length Principle;  Transfer Pricing Methods;  Administrative Procedures;  Instructions for Tax Authorities;  Advance Pricing Arrangements;  Transfer Pricing of Non-Material Assets & Services.

No Regulation System Some Legislative Provision: the Law of Ukraine "On Corporate Income Tax" the Law of Ukraine "On the Value Added Tax” Resolution of the National Bank of Ukraine №597 "On transfer of funds in national and foreign currency to non-residents for Certain Transactions”

I Stage: 1)Publishing Special Legal Document 2)Holding Trainings for Controllers 3)Restructuring Tax Administration II Stage: 4)Implementing Transfer Pricing Methods 5)Applying Sanctions for Abuse of Transfer Pricing III Stage: 6) Regulating Transfer Pricing for Non-Material Assets